Taxation of other income: taxable only in resident state, except income connected to permanent establishment or fixed base or gambling. Income of a resident not dealt with elsewhere in the Convention is taxable only in the resident State, subject to two exceptions: income (other than immovable property income) effectively connected with a permanent establishment or fixed base in the other State is taxable under the rules for business profits or independent personal services; and income from lotteries, betting, gambling and similar games sourced in the other State may be taxed in that source State.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Taxation of other income: taxable only in resident state, except income connected to permanent establishment or fixed base or gambling.
Income of a resident not dealt with elsewhere in the Convention is taxable only in the resident State, subject to two exceptions: income (other than immovable property income) effectively connected with a permanent establishment or fixed base in the other State is taxable under the rules for business profits or independent personal services; and income from lotteries, betting, gambling and similar games sourced in the other State may be taxed in that source State.
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